Privacy Policy

Data Protection and Data Safety Policy

I. GENERAL PROVISIONS

1. Purpose and scope of the Policy

This policy (Policy) stipulates provisions with respect to the protection of personal data of natural persons and the free movement of personal data. The provisions of this Policy shall be applied in the course of specific data control activities as well as when disclosing data control instructions and information. In order to comply with the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information and the General Data Protection Regulation (EU) No. 2016/679 of the European Parliament and of the Council CarehomeNet Zrt. (Data Controller) has underlined this Policy and it shall be bound by these provisions when providing its services.

The purpose of this Policy is to harmonize the provisions of certain internal policies governing data control of the Data Controller in order to protect fundamental rights and freedom of natural persons and to ensure the appropriate control of personal data. Another important purpose of the Policy is that the employees and sub-contractors of the Data Controller could control the personal data of natural persons lawfully by reading and following this Policy.

The Policy shall apply to:

  • all employees, sub-contractors of the Data Controller and to persons carrying out data control and data processing activities on the basis of an agreement with the Data Controller as well to persons who have access to personal data controlled by the Data Controller based on any legal ground;
  • the flow of data towards the data processors and to the activity of those data processors unless otherwise agreed;
  • the flow of data towards addressee of data transfer;
  • the data transfer, data exchange and co-dataprocessing activities pursued by the Data Controller together with other data controllers or third persons.

This Policy shall apply to all kind of data control and data transfer activities and information exchange concerning personal data pursued or supervised by the Data Controller and to all other activities pertaining to the protection of data control being the subject of these data control and information exchange activities and to all technical operations involved in data control irrespective of the place where the control or processing takes place and irrespective of their form.

This Policy shall apply to all personal data which is controlled by the Data Controller in an electronic format or other format (e.g. paper-based) and which is stored, processed, transferred by the Data Controller or to which it has access.

2. Applicable laws and internal policies

The following laws are relevant with respect to the data control which laws can change from time to time. In case of change of law the change stipulated by the effective law shall be taken into account at the relevant part of the Policy and the Data Controller shall take the necessary measures in order to change the Policy as soon as possible.

Important relevant laws:

  • Regulation (EU) No. 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
  • Act V of 2013 on the Civil Code
  • Act I of 2012 on the Labour Code
  • Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information
  • Act C of 2000 on Accounting

3. DEFINITIONS

Should there be any discrepancies between the following the definitions and the definitions determined in the laws, the definitions laid down in the laws shall prevail.

  • data control: shall mean any operation or set of operations that is performed upon data, whether or not by automatic means, such as in particular collection, recording, organization, separation, storage, adaptation or alteration, query, inspection, use, retrieval, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction;
  • data processor: shall mean a natural or legal person that is engaged in the processing of personal data in the name of the Data Controller or on the basis of an engagement by the Data Controller;
  • personal data: shall mean any information relating to an identified or identifiable person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, number, location data, online identification number or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • the data subject’s consent shall mean any freely and expressly given specific and informed indication of his/her wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
  • restriction of data control shall mean the marking of stored personal data with the aim of limiting their control in the future;
  • filing system shall mean any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
  • personal data breach shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processe

4. Possible differences between certain policies and rules

The Company shall be considered Data Controller with respect to some of the services indicated below whilst it shall be considered data processor in relation to some other services. The data processing activities shall be governed by the agreement concluded with the Data Controller and its annexes. In the event of any discrepancies, the legal provisions shall prevail except where the legislation allows deviation. In these cases the provisions of this data protection and data safety policy and the agreement concluded with the Data Controller shall be applied.

5. Principles relating to the processing of personal data

Personal data may be controlled only for specified and explicit purposes, where it is necessary for the implementation of certain rights or obligations. The purpose of control must be satisfied in all stages of data control operations; recording of personal data shall be done under the principle of lawfulness and fairness. The personal data controlled must be essential for the purpose for which it was recorded, and it must be suitable to achieve that purpose. Personal data may be controlled to the extent and for the duration necessary to achieve its purpose in accordance with the provisions of this Policy.

Before controlling operations are carried out the data subject shall be clearly and elaborately informed of all aspects concerning the control of his/her personal data, such as the purpose for which his data is required and the legal basis, the person entitled to control the data and to carry out the processing, the duration of the proposed controlling operation, if the data subject’s personal data is processed in accordance with Subsection (5) of Section 6 of the Act on the Right of Informational Self-Determination and on Freedom of Information, and the persons to whom his/her data may be disclosed.

Accountability: the Data Controller is responsible for the compliance with the following principles, furthermore it must be able to verify such compliance. Should the Data Controller carries out data processing activities, it shall provide maximum assistance in order to ensure the compliance and accountability of these principles.

(1) Lawfulness, fairness and transparency

The personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject;

(2) Purpose limitation

The personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes;

(3) Data minimisation

The personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed

(4) Accuracy

The personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay

(5) Storage limitation

The personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject.

(6) Integrity and confidentiality

The personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

As from 25 May 2018 the data control shall be lawful only if and to the extent that at least one of the following applies:

(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

(c) data control is necessary for compliance with a legal obligation to which the Data Controller is subject;

(d) data control is necessary in order to protect the vital interests of the data subject or of another natural person;

(e) data control is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;

(f) data control is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
 

The legal basis of the data control carried out by the company is summarised in the below table:

Data controlled

Categories of data

Legal basis

 

Visitors of the website

Information stored in the cookie

Consent

Data of the subcontractors

Contact details

Balance of interest based on legitimate interest

Legitimate interest: Company’s interest to business continuity

Data of employees

Data specified by the Art on the Rules on Taxation and other acts

Fulfilment of legal obligations

Data relating to the provided services

Data provided voluntarily and compulsorily at the time of the registration by the User and the Institution. The data to be provided voluntarily and compulsorily are specified in the General Terms and Conditions

Consent or balance of interest based on legitimate interest by the customer if we use data made public on public portals for the purpose of networking

Legitimate interest: enhancement of the provision of elder care and similar services.

Complaint handling

Contact details

Balance of interest based on legitimate interest

Legitimate interest: Company’s interest to business continuity

Newsletter, direct marketing activities

Contact details

Consent

Data control of community sites

Name, profile picture, any shared data

Consent

 

Certain data controls are detailed in Section II.7. hereof.

6. Data processing, use of hosting provider

The Company as Data Controller uses data processors: employees, subcontractors who have accepted the provisions of this Policy and who has a confidentiality obligation.

Data Controller uses the following data processors at the moment:

Melkweg Kft., 1036 Budapest, Pacsirtamező u. 41.
Melkweg is providing operation and IT development services with respect to the websites of the Data Controller.

KBOSS.hu Kft, 1031Budapest, Záhony utca 7.
KBOSS.hu Kft, is providing invouicing services with respect to the websites of the Data Controller with the assistance of the szamlazz.hu system.

Accountant
Audito Kft., 2112 Veresegyház, Bárdos Lajos u. 22.

Data Controller uses the following hosting provider at the moment:
DoclerNet Hosting Kft. 1101 Budapest, Expo tér 5-7.

7. Right to appeal:

The executive officers of the Data Controller shall continuously inspect the compliance with the requirements of the legal provisions relating to data control and the internal regulatory documents.

The executive officers of the company are entitled to inspect the compliance of the lawful data control by reviewing the internal regulatory documents, minutes and records.

Supervisory authority:

National Media and Infocommunications Authority

1125 Budapest, Szilágyi Erzsébet fasor 22/C.

If you wish to take judicial remedy: the General Courts have competence. The general court seated at the address of the data subject shall have competence.

II. DETAILED RULES

1. Data transfer of personal data

The Company shall ensure that the data protection requirements and guarantees are incorporated in the agreement to be concluded with the person and institutions carrying out data control and data processing services on the basis of the engagement of the Company or in the name of the Company.

2. Lodging complaints/claims

Lodging complaints to the Company:

The Company may provide several possibilities for making claims relating to certain Service of the Company: in writing, by e-mail. If the Company provides for a possibility of lodging claims by e-mail than the claim received from the e-mail address – exclusively this e-mail address- provided previously to the Company in connection with the Services shall be considered as a claim received from the Person Concerned.

If the data control is not based on consent but it was initiated by a third person abusively, than the person concerned shall have the right to request the erasure his/her personal data which was published by a third person, furthermore the person concerned shall have the right to request information about the data control of his/her personal data by verifying his/her identity and the connection with the personal data.

The Data Controller has 30 days for handling the complaint however it makes its best effort to reply to all complaints and claims as soon as possible.

3. Rights of the data subjects and their enforceability

THE DATA SUBJECT’S RIGHT TO INFORMATION

The Data Controller obtains the personal data especially from the data subject, the Data Controller shall provide the data subject with the following information upon request:

  • the identity and the contact details of the Data Controller and of the Data Controller's representative;
  • the contact details of the data protection officer of the Data Controller;
  • the purposes of the data control activities for which the personal data are intended as well as the legal basis for the data control;
  • the categories of personal data concerned; the recipients or categories of recipients of the personal data, if any; where applicable, that the controller intends to transfer personal data to a recipient in a third country than the information described in the GDPR;
  • the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  • where the data control is based on balance of interest, the legitimate interests pursued by the Data Controller;
  • the existence of the right to request from the Data Controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability;
  • where processing is based on consent, the existence of the right to withdraw consent at any time, without affecting the lawfulness of data control based on consent before its withdrawal;
  • the right to lodge a complaint with the National Media and Infocommunications Authority;
  • from which source the personal data originate, and if applicable, whether it came from publicly accessible sources;
  • the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  • the right to information may only be denied in cases defined in Subsection (5) of Section 14 of GDPR.

RIGHT OF ACCESS BY THE DATA SUBJECT

The data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

  • the purposes of the data control;
  • categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the Data Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such data control;
  • the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The Data Controller shall provide a copy of the personal data undergoing processing upon request. For any further copies requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others.

RIGHT TO RECTIFICATION AND TO ERASURE

The data subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

The Data Controller shall have the obligation to erase personal data without undue delay upon the request of the data subject:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise controlled;
  • the data subject withdraws consent on which the data control is based and where there is no other legal ground for the data control;
  • the data subject objects to the data control and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing purposes;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  • the personal data have been collected in relation to the offer of information society services provided to children.

The Data Controller shall communicate any rectification or erasure of data control to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Data Controller shall inform the data subject about those recipients if the data subject requests it.

RIGHT TO RESCTRICTION OF DATA CONTROL

The Data Controller shall restrict the data control upon request of the data subject if:

  • the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data;
  • the data control is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • the Data Controller no longer needs the personal data for the purposes of the data control, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  • the data subject has objected to data control carried out on the basis of legitimate interest or public interest, the verification whether the legitimate grounds of the controller override those of the data subject.

The Data Controller shall communicate any restriction of data control to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Data Controller shall inform the data subject about those recipients if the data subject requests it.

RIGHT TO DATA PORTABILITY

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Data Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

  • the data control is based on consent or on a contract pursuant to the General Data Protection Regulation; and
  • the data control is carried out by automated means.
  • the provisions of the General Data Protection Regulation shall be applied to the restriction or exclusion of the right to data portability.

RIGHT TO OBJECT

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to data control of personal data concerning him or her which is carried on the basis of legitimate interest or public interest, including profiling based on those provisions. The Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the data control which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

At the latest at the time of the first communication with the data subject, the right referred to above shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

4. Incident treatment as a Data Controller

In the case of a personal data breach, the Data Controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the National Media and Infocommunications Authority. The notification shall be done in a format and in a manner required by the supervisory authority (e.g. through a platform or hot-line), if there are requirements like that prescribed by the supervisory authority. If there is no platform, than the notification shall be done with the compulsory elements.

  • If the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons, no notification needs to be made. This decision shall be made by the managing director by taking into account all relevant requirement.
  • The Data Controller shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. If the supervisory authority requires certain mandatory elements to be contained in the documentation, that the documentation shall meet this criteria.
  • When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the Data Controller shall communicate the personal data breach to the data subject without undue delay. This decision shall be made by the managing director by taking into account all relevant requirement and he/she shall make a notice of that decision.
  • The communication to the data subject shall not be required if any of the following conditions are met:
  • the Data Controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption; (b) the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialise; (c) it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.

5. Data safety rules

Personal data must be specially protected with appropriate measures against unlawful access, alteration, transfer, disclosure, erasure and destroy, and accidental consummation and injury as well as against unreachability due to the change of the techniques involved.

When determining and applying the provisions relating to data safety, the Data Controller shall take into account the state of the current technology knowledge. Among more possible data control solutions that one has to be chosen which ensures higher level protection for the personal data, except that would constitute a disproportionate difficulty for the Data Controller.

All necessary measures need to be taken in order to be able to implement the data safety rules with respect to personal data processed manually and with respect to personal data stored and processed through a computer.

The following principles shall be taken into account when developing the safety measures:

  • Awareness: all people using IT systems shall know the safety methods and processes in order to enhance trust in IT systems.
  • Responsibility: the responsibility relating to safety of the IT systems’ owners and supporters shall be express and clear.
  • Proportionality: the safety categories and measures shall be appropriate and proportionate with the value and reliability criteria of the protected system, with the costs of the enhancement of the safety and with the severity and possibility of damages arising out of the possible breach of the safety measures.
  • Risk proportionate safety measures.
  • Actuality: safety must be reconsidered frequently and must be updated according to the change in the risks and consequences arising out of the possible breach of safety.
  • Integrity: a coherent and integrated safety approach is needed with respect to all elements of an information system.
  • Reaction mechanism: all participants shall cooperate in order to prevent security breaches and in order to provide quick answer with respect to a breach.

6. Management of physical danger

In order to prevent unlawful access, the physical safety system shall be made suitable for prevention against unauthorised access and the operators of these systems shall be able to detect and prevent these and to prevent the unauthorised use of the equipment.

The actual anti-virus system shall be installed at every workstation, the updates (especially virus definitions) due regularly shall be downloaded and installed.

7. Certain data control activities

The data control of the visitors of the Website

The Data Controller provides the following information in relation to analytical tools, the so called cookies (süti in Hungarian) according to Subsection 4 Section 155 of Act C of 2003 on Electronic Communications “On the electronic communication terminal equipment of a subscriber or user, information may be stored, or accessed, only upon the user’s or subscriber’s prior consent granted in possession of clear and comprehensive information about implications”

The Data Controller uses the following cookies, the purposes of which are indicated below:

Strictly necessary cookies

These cookies are essential for the use of the website. Without the acceptance of these cookies, the Data Controller cannot guarantee the appropriate functioning of the website as intended, nor the accessibility of all searched information by the user. These cookies do not collect any personal data from the data subjects or data which can be used for direct marketing purposes.

Strictly necessary cookies for instance are the performance cookies which collect information as to whether the website functions properly or whether there are any mistakes in its functioning. By notifying the Data Controller about possible mistakes these cookies provide assistance to the Data Controller for the improvement of the website and they show which parts of the website are the most popular.

Functionality cookies

These cookies ensure the coherent appearance of the website tailored to the needs of the data subjects, and they remember the choices the data subjects made (e.g. colour, character size, layout).

This cookie furthermore helps the improvement of the development of the ergonomics and in the development of a user-friendly website, as well as the enhancement of the online experience of the visitors.

Tracking cookies

The data control of these cookies take place on the basis of Subsection 3 of Section 13/A of Act CVIII of 2001 on Electronic Commerce and on Information Society Services

The duration of the data control is until the closure of the relevant work session of the visitor. The purpose of the data control is the identification of new sessions and the visitors, and the operation of Google Analytics tracking services of the website. The cookies of GoogleAds and Facebook are in use as well.

Use of GoogleAdwords

The Data Controller use Google Adwords remarketing service, furthermore it uses conversion tracking services of Google within the framework of Google Adwords. The conversion tracking of Google is the analytical service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA94043, USA “Google”).

If a visitor reaches out a website through a Google advertisement, than a cookie necessary for conversion tracking is downloaded to his/her computer. The validity of these cookies is limited and they do not contain any personal data therefore the users cannot be identified by those.

When the user browse certain pages of the website and the cookie is not expired yet, than the Data Controller and Google are able to check which advertisement were looked by the user.

All GoogleAdwords client receives separate cookies therefore those cannot be tracked through the website of GoogleAdwords clients.

The purpose of the information gained by the use of conversion tracking cookies is to prepare conversion statistics for the clients choosing conversion tracking of Adwords. The clients can orientate themselves about the number of users clicking on their advertisement and forwarded to a site labelled with conversion tracking. However they do not receive any information on the basis of which they could identify the users.

If you do not wish to participate in the conversion tracking, than you can decline it by rejecting the download of cookies in your browser. Following this you will not appear in conversion tracking statistics.

Further information and the privacy policy of Goole can be found at the following link: www.google.de/policies/privacy

Use of Google Analytics

The Google Analytics uses so-called cookies, word files which are stored at your computer and which facilitate the analysis of the use of the website.

The information generated by the cookies used by the Users are usually forwarded and stored at one of the server of Google in the USA. By activating the IP- anonymization Google previously abbreviates the IP address of the User in the European Union and in the member states of the Agreement on the European Economic Area.

The transfer of the whole IP address to the US server of Google and the abbreviation of it there only takes place exceptionally. On the basis of the engagement of the operator of this website, these information will be used by Google in order to evaluate how the User browsed the website and to prepare reports to the operator of the website with respect to the activity of the website, furthermore to provide further services in connection with the use of the website and the internet.

The IP address forwarded by the browser of the User within the framework of Google Analytics is not reconciled with other data of Google. The User can prevent the storage of cookies by setting up its browser appropriately, however your attention is drawn to the fact that not all functions of the website can be fully used in this case. Furthermore you can prevent the collection and storage the data connected to the use of the website through cookies, by downloading and installing plugin which can be found at the following website: https://tools.google.com/dlpage/gaoptout?hl=hu

Data control of customers (Users and Institutions)

The data control carried out in order to perform the services shall be considered as data control of the customers. The purpose of the data control is the efficient fulfilment of the services in accordance with the provision of the contract and by providing appropriate contact. In this case the data of the contact person (name, address, telephone number, e-mail address) indicated in the contract between the Data Controller and the customer will be stored in particular. The legal basis of the data control is the fulfilment of the agreement between the Data Controller and the customer.

The scope of the data controlled is the personal data indicated in the agreement between the Data Controller and the customer which is provided at the time of the registration. The GTC contain the data which must be provided compulsory and the ones which can be given voluntarily.

The customer data can only be accessed by the managing director of the Data Controller and its employees and subcontractors.

The customer data shall be treated confidentially, apart from the above-mentioned person no other person shall be entitled to get to know them.

The duration of the data control is until the fulfilment of the agreement, and it can be 8 years according to Subparagraph 2 Section 169 of Act C of 2000 on Accounting.

Data Control of subcontractors

The purpose of the data control is data control of data essential to the contact with respect to the agreements concluded with subcontractors. The data control is based on the agreement between the Data Controller and the subcontractor.

The scope of the data controlled are the personal data indicated in the agreement between the Data Controller and the subcontractor, especially the name of the contact person, telephone number, e-mail address, contact address.

The data of the subcontractors can only be accessed by the managing director of the Data Controller and its employees and its engaged accountant.

The duration of the data control is until the fulfilment of the agreement, and it can be 8 years according to Subparagraph 2 Section 169 of Act C of 2000 on Accounting.

Data control of employees

When establishing an employment relationship, the employee gives personal data necessary for the establishment of the employment relationship, and for the exercise of rights and fulfilment of obligations arising out from the employment relationship to the Data Controller. Except these data the Data Controller does not collect and control any further data relating to the employees. The legal basis of the data control is the consent of the employee and the Labour Code.

The data which are controlled are the followings:

  • the personal data stipulated in the Act on the Rules of Taxation;
  • the personal data stipulated in the Act on the Eligibility for Social Security Benefits and Private Pensions and the Funding for These Services
  • the personal data stipulated in the Act on the Services of the Compulsory Health Insurance System

The employee data can only be accessed by the managing director of the Data Controller and its engaged accountant.

The Data Controller shall have the right to send its employees to compulsory medical suitability examination annually. The suitability document issued on the basis of this examination shall be handed over to the Data Controller, but this document can only contain the information – apart from the personal data of the employee – whether the employee is suitable for the position or not. Accordingly, no sensitive data is controlled with respect to the employees nor for the purpose of medical suitability examination nor for other purposes.

The duration of the data control is the last day of the 6th calendar year following the termination of the employment relationship.

Newsletter, direct marketing

On the basis of Section 6 of Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities the Service Provider may reach out the Users with advertisements and other deliveries at the availabilities provided by them at the registration if the Users have provided their express and prior and consent to that.

The User may give its consent to the data control of its personal data necessary for the sending of advertisement by the Service Provider by taking into account the provisions of this policy.

The Service Provider does not send unrequested advertisements and the User shall be entitled to unsubscribe from any newsletter without any limitation and without having to justify it. In this case, the Service Provider erases all of the personal data– necessary for the sending of advertisements – of the requesting person from its records and it does not reach out the Users with further advertisements. The User may unsubscribe from the newsletter by clicking on the link indicated in the message.

The fact of the data control, the scope of the data controlled and the purpose of the data control:

Personal data: name, e-mail address, IP address, date of subscription

Purpose of the data control: Identification, making possible the subscription to newsletters

Data subjects: everyone subscribing on the newsletter

Purpose of the data control: sending electronic messages (e-mail, text, push message) containing advertisements to the data subjects, providing information about the actual information, products, sales, new functions etc.

The duration of the data control, the erasure of data: until the withdrawal of the consent, that is the unsubscribe.

Possible data controllers entitled to access the data, the addresses of the personal data:

The personal data may be controlled by the sales and marketing employees of the Data Controller in compliance with the above principles.

The rights of data subject in connection with the data control:

  • The data subject shall have the right to request access to his/her personal data from the data controller, to request the rectification and erasure of his/her personal data, and to request the restriction of the data control.
  • The data subject shall have the right to object against the data control of his/her personal data
  • The data subject shall have the right to data portability and to withdraw his/her consent at any time.
  • The data subject may unsubscribe from the newsletter at any time and for free of charge.

The legal basis of the data control: Points a) and f) of (1) Section of Article 6 and Subsection 5 of Section 6 of Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities.

Complaint handling

The fact of the data control, the scope of the data controlled and the purpose of the data control:

Personal data: first name and last name, e-mail address, telephone number, invoicing name and address

Purpose of the data control: Identification, Handling of the objections complaints relating to the quality of the ordered products and the questions and other problems.

Data subjects: everyone making a quality complaint

The duration of the data control, the erasure of data: the copies of the record made about the complaint and the replies shall be kept for a period of 5 years according to Subsection 7 Section 17/A of Act CLV of 1997 on Consumer Protection.

Possible data controllers entitled to access the data, the addresses of the personal data:

The personal data may be controlled by the sales and marketing employees of the Data Controller in compliance with the above principles.

The rights of data subject in connection with the data control:

  • The data subject shall have the right to request access to his/her personal data from the data controller, to request the rectification and erasure of his/her personal data, and to request the restriction of the data control.
  • The data subject shall have the right to object against the data control of his/her personal data
  • The data subject shall have the right to data portability and to withdraw his/her consent at any time.

The legal basis of the data control: Point c) of (1) Section of Article 6 and Subsection 7 Section 17/A of Act CLV of 1997 on Consumer Protection.

The data control made on community websites:

Personal data: registered name on the following community websites Facebook, Google +, Twitter, Pinterest, Youtube, Instagram etc. and the public profile picture.

Purpose of the data control: Sharing and popularizing certain elements, products and sales of the website of community websites.

The duration of the data control, the erasure of data, possible data controllers entitled to access the data, the rights of the data subject: The data subject may orientate about the source and control of the data, and the method and legal basis of the transmission on the community websites. The data control takes place on the community websites therefore the rules relating to the duration, method of the data control and the right to erasure and modification can be found on those websites.

The legal basis of the data control: the consent of the data subject.

8. CLOSING PROVISIONS

This Policy becomes effective on the day following the acceptance of it by the managing director of the Data Controller while the previous policy becomes ineffective on that day and the forms, declarations, templates relating to it cannot be used in the future.

 

Budapest, 1st of December, 2018